0What the EUDR requires for coffee
Three conditions, all at the same time
Regulation (EU) 2023/1115, known as the EUDR, only lets coffee be placed on the EU market, or exported from it, if three conditions are met at the same time (Art. 3):
| Condition | What it means |
|---|---|
| Deforestation-free | No deforestation on the plot of land after 31/12/2020. |
| Legally produced | Compliance with the relevant legislation of the country of production: land use, environment, labour, human rights, third-party rights, tax, among others (Art. 2(40)). |
| Statement filed | A due diligence statement (DDS) filed in the EU Information System before placing on the market or export. |
| Code | Product (Annex I) |
|---|---|
| 0901 | Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee. |
| 2101 11 00 | Extracts, essences and concentrates of coffee, including instant coffee. Applies from 30/12/2027. |
1Who is responsible
Your European buyer will ask you
The operator is, as a rule, whoever is declared as the importer in the EU customs declaration. It files the DDS and bears legal responsibility. A Brazilian exporter selling to a European importer is usually not the operator.
But the importer can only file the DDS if it receives the geolocation of the plots and the evidence of legality and of no deforestation. In practice, whoever cannot deliver this data loses the buyer.
2Where coffee needs most preparation
The points that need most attention in the chain
| Topic | What the EUDR requires |
|---|---|
| Geolocation | Coordinates with at least 6 decimal places and a polygon for plots over 4 ha (Art. 2(28)), across a base with many small and medium producers. |
| Mixing of lots | Blends, reprocessing and public warehouses. Mass balance is not accepted; in warehouses without regular emptying, everything received must be declared until it covers at least 200% of capacity (FAQ 1.17). |
| Intermediaries | Brokers, local processors and other cooperatives between the farmer and the exporter must pass on the origin per plot. |
| Legality | CAR rural registry, Legal Reserve and permanent preservation areas, land tenure, NR-31, the forced labour register, environmental embargoes. |
| Data for the DDS | Product code, quantity, country and plots, complete and consistent for each shipment. |
| Contracts | EUDR clauses with suppliers and with the European buyer: data required, deadlines, blocking and liability. |
3How we work
End-to-end consulting, with a geospatial technology partner
Brasil Sustentabilidade leads the consulting and organises due diligence. A geospatial technology partner handles digital document collection, plot analysis and the traceability platform. Contracts are separate: the client hires each one directly, and the workflow is integrated.
| Activity | Brasil Sustentabilidade | Technology partner | Client |
|---|---|---|---|
| Assessment and action plan | Carries out | Supports with data | Provides information |
| Due diligence procedure | Drafts | — | Approves and applies |
| Producer documents and geolocation | Sets rules and list | Collects and validates | Engages suppliers |
| Deforestation and restrictions analysis | Checks and handles exceptions | Carries out | Decides the purchase |
| Lot and warehouse traceability | Designs the rules | Platform | Runs it day to day |
| Data package for the importer | Organises and reviews | Generates the files | Sends to the buyer |
4The five stages
Standardised scope, pricing on proposal
| Stage | What we deliver |
|---|---|
| 0 · Screening | Readiness questionnaire and scope of the proposal. |
| 1 · Assessment | Supply chain map, the client's role under the EUDR, prioritised gaps and action plan. |
| 2 · Structuring | Due diligence procedure, traceability rules (lots, blends, warehouses), document list, contract clauses, data package template and training. |
| 3 · Technology | By the partner: producer and plot base analysed and geolocation files per shipment. |
| 4 · Follow-up | Periodic review, internal audit by sample, regulatory updates and support with the buyer's audits. |
5What it is and what it is not
Transparency from the first contact
| It is | It is not |
|---|---|
| Preparation to comply with the EUDR, with method and organised evidence. | Certification: the EU recognises no official EUDR label, and no label replaces the DDS. |
| Support for the client and its buyer to carry out due diligence. | A transfer of responsibility: the operator remains responsible. |
| A basis for a future independent verification by a third party. | Verification of the same client by Brasil Sustentabilidade: whoever prepares does not verify. |
6How to start
Four steps to the assessment
- Initial conversation to understand the operation and the buyers in the EU.
- Screening: you answer the readiness questionnaire.
- Proposals: Brasil Sustentabilidade and the technology partner send their own proposals.
- Start: kick-off meeting and beginning of the assessment.
To make a proposal, we need to know: the volume exported to the EU, who is the declared importer, the number of suppliers and producers, the regions of origin, whether you use your own or third-party warehouses, whether you blend or reprocess and which systems you use.
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Shall we prepare your coffee for Europe?
Tell us about your operation. We reply with the screening and the scope of the proposal.